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Found 2 results

  1. For single employer plans, we currently have a "standard" approach to determine the expected return on assets for asset smoothing and actual ROA used for rolling FSCB/PFB forward. This approach involves an assumption that annuity cashflows generally happen at the middle of year, and expenses are paid at the end of the year. We have a couple of plans that we received as part of an acquisition several years ago that reflect actual cashflow timing to the day. We would like to move them to our "standard" approach to be able to take advantage of processes and tools we have built. Any change would be very minor. Looking for opinions or guidance on whether adjusting the assumed cashflow timing in these calculations amount to a change in funding method. I haven't been able to find anything in Gray Books, regs, revenue notices, etc. that gets to this level of minutia which makes me think we should be fine to make the change without having to file with the IRS for approval.
  2. I have 2 plans that are sponsored by the same company. They want to merge the 2 plans to make administration easier. One plan has a funding shortfall in the year before the merger and the other plan did not have a funding shortfall. Based on Rev. Proc. 2017-56, it seems like due to the fact that one plan had a shortfall and the other did not, that it does not qualify for an automatic approval. Therefore, we are requesting approval for a change in funding method. Does anyone know if this is required? As of the merger date, due to the assets in the 2nd plan, all shortfall amortizations are wiped out and the plan is over 100% funded. From what I can find in Rev. Proc. 2017-4, the user fee is $10,000. This seems excessive given the fact that one company sponsors both plans and the only reason they did not qualify for the automatic approval was the funding shortfall, which is taken care of as soon as the merger takes place.
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